Biomethane production

The Renewable Energy Directive III (RED III) is the latest version of the EU Renewable Energy Directive, which came into force on 20 November 2023. It replaces RED II from 2018 and pursues the overarching goal of increasing the share of renewable energies in EU-wide final energy consumption to at least 42.5% by 2030, setting sector-specific sub-targets for transport, buildings and industry, and accelerating approval procedures.

RED III contains far-reaching provisions for biogas and biomethane plants, affecting both new and existing plants. Among other things, the greenhouse gas reduction requirements for biogenic fuels and combustibles have been increased. The directive represents both an opportunity for the further expansion of renewable energies and a considerable challenge for existing biogas and biomethane plants, which may have to fundamentally adapt their operating modes.

According to Article 29(1) RED III, sustainability requirements in accordance with paragraphs 2 to 7 and 10 must be met when gaseous biomass fuels are used in installations for the production of electricity, heating and cooling with a total rated thermal input of at least 2 MW or are produced in biomethane production installations with a capacity exceeding 200 Nm³/h.

According to Article 29(10)(d)-(e) RED III, the following reductions in GHG emissions must be achieved in electricity, heating and cooling production:

• At least 80% for new installations commissioned after 20 November 2023 that use biomass fuels
• At least 70% by 31 December 2029; at least 80% from 1 January 2030 for plants ≥ 10 MW with IBN between 1 January 2021 and 20 November 2023 that use biomass fuels
• At least 70% under 15 years of operation; At least 80% after 15 years in operation for plants ≤ 10 MW with IBN 01.01.2021 to 20.11.2023 that use gaseous biomass fuels
• At least 80% after 15 years in operation for plants ≥ 10 MW with IBN before 01.01.2021; From 1 January 2026 at the earliest/31 December 2029 at the latest, using biomass fuels
• At least 80% after 15 years of operation for plants ≤ 10 MW with IBN before 1 January 2021; From 1 January 2026 at the earliest, using gaseous biomass fuels

For biomethane production plants with a capacity of more than 200 Nm³/h, the following minimum GHG savings are envisaged in accordance with Article 29(10)(a)-(c) RED III if they wish to market biomethane as a biofuel in transport:

• 50% if the plant commenced operation on or before 5 October 2015
• 60% if the plant commenced operation between 6 October 2015 and 31 December 2020
• 65% if the plant commenced operation on or after 1 January 2021

According to Article 29(15) RED III, there is a grandfather clause, but this is only a discretionary provision. According to this provision, until 31 December 2030, energy from biofuels, liquid biofuels and biomass fuels may also be taken into account for the purposes referred to in paragraph 1, subparagraph 1, points (a), (b) and (c) of this Article if:

• support was granted before 20 November 2023 in accordance with the criteria for sustainability and GHG emission savings set out in Article 29 in the version applicable on 29 September 2020
• long-term support was granted for which a fixed amount was set at the beginning of the support period and provided that a correction mechanism is in place to ensure that there is no overcompensation.

Germany has so far only partially implemented RED III, e.g. for wind energy. An amendment to the Biomass Electricity Sustainability Ordinance (BioSt-NachV) is pending, but may still be planned for 2025.

Source: Directive (EU) 2023/2413